Office of Foreign Assets Control

News & Analysis as of

OFAC Announces Settlement with Money Services Business for Violations of Sanctions Programs

On March 23, Department of the Treasury’s OFAC announced a settlement agreement with a large money services business (MSB) for failing to implement an effective compliance program “to identify, interdict, and prevent...more

U.S. Government Announces Significant Sanctions Enforcement Actions Against Schlumberger and PayPal

The U.S. Government announced two major sanctions enforcement actions this week that reinforce the compliance challenges faced by both U.S. companies with international activities and non-U.S. companies subject to U.S....more

OFAC Adds 7 Venezuelan Officials to SDN List

On March 8 President Obama signed Executive Order 13692 Executive Order 13692, which initially adds seven former or current Venezuelan government officials to OFAC’s Specially Designated Nationals (SDN) List. Once they have...more

Inadequate Screening Processes Result in $7.65 Million Settlement for Violations of Various U.S. Sanctions Programs

On March 25, 2015, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and PayPal, Inc. (“PayPal”) agreed to a $7.65 million settlement to settle potential civil liability for 486 apparent...more

PayPal To Pay Dearly for Alleged Violations of OFAC Sanctions

The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has announced a $7,658,300 settlement with PayPal, Inc. (PayPal) to resolve potential civil liability for 486 alleged violations of the Iranian,...more

Restrictions Eased for Communications-Related Items Exported to Sudan

On February 18, 2015, in a coordinated action, the Commerce Department's Bureau of Industry and Security (BIS) and Treasury Department's Office of Foreign Assets Control (OFAC) announced and implemented changes to the...more

OFAC Announces New Ukraine-Related Designations, Includes Russian National Bank

On March 11, OFAC updated its Specially Designated Nationals (SDNs) list comprising of individuals and entities including a Russian national bank, Russian National Commercial Bank. ...more

New York's Lawsky Proposes SOX-Style Personal Accountability for Anti-Money Laundering, Foreign Asset Compliance

It is, by now, common practice for financial institutions (and other businesses as well) to adopt and maintain comprehensive and costly Anti-Money Laundering (AML) and Office of Foreign Assets Control (OFAC) compliance...more

FinCrimes Update - February 2015 Summary, Volume 2, Issue 2

On February 25, New York DFS Superintendent Benjamin Lawsky delivered remarks at Columbia Law School focusing on how state bank regulators can better supervise financial institutions in a post-financial crisis era. In his...more

US Imposes Additional Ukraine/Russia- Related Sanctions By Designating Individuals and Entities Pursuant to Executive Orders 13660...

On March 11, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued further designations pursuant to Executive Order 13660 (EO 13660) and Executive Order 13685 (EO 13685). EO 13660, which was...more

Sharing Sensitive Technologies Between International Affiliates

In the normal course of operations between U.S. and foreign affiliates, inter-company communications and data conveyances are frequent and occur both intentionally and inadvertently. The U.S.-foreign affiliation can be in the...more

The Need for Robust OFAC Compliance Programs

People are good at complaining. People often say to themselves, “Things are not going my way,” and they love to feel sorry for themselves. People who are professional victims are toxic....more

Cuban Baseball Players Are No Longer Required to Obtain a License to Play Ball

Earlier this month, Major League Baseball eliminated a burdensome requirement that made it difficult for MLB franchises to sign Cuban nationals. Until last month, a Cuban national wanting to sign with a MLB franchise as a...more

Bridging the Gap to Cuba

Last December, President Barack Obama announced a series of changes to the United States’ policy toward Cuba. The most significant changes, from a foreign policy perspective, included restoring diplomatic relations with Cuba...more

New Authorizations to Export Personal Communications Items and Services to Sudan

On February 18, 2015 the Commerce Department’s Bureau of Industry and Security (“BIS”) and Treasury Department’s Office of Foreign Assets Control (“OFAC”) published changes to the Export Administration Regulation (“EAR”) and...more

US State Department Issues Section 515.582 List Regarding Authorization of Imports of Certain Goods and Services Produced by...

On February 13, 2015, the US Department of State published its “Section 515.582 List” and related guidance regarding the goods and services produced by independent Cuban entrepreneurs which have been authorized for immediate...more

Cuba Sanctions: 10 Important Changes

Ten key changes to US sanctions and export regulations for Cuba. On January 15, 2015, the Departments of the Treasury and Commerce revised the Cuban Assets Control Regulations (CACR) and the Export Administration...more

"Implications of National Security Reviews on Foreign Acquisitions of US Businesses"

The Committee on Foreign Investment in the United States (CFIUS) can have a significant impact on transactions involving foreign acquirers. Parties considering cross-border merger and acquisition transactions should be aware...more

Know the Risks: Domestic and International Compliance

The penalties for compliance missteps have never been higher — particularly in the international regulatory context. As the record-setting penalties against BNP Paribas (nearly $9 billion in penalties for violations of...more

U.S. Sanctions Update

Recent actions by the U.S. Congress and several executive branch agencies have resulted in changes to sanctions related to various countries and regions, including Cuba, North Korea, Crimea, and Venezuela....more

Sanctions Update: Continuing Implementation of US Embargo of Crimea Region

New US rules define scope of prohibitions and authorized activities, as Crimea region remains subject to broad US embargo and EU trade and investment restrictions. On January 29 and 30, 2015, the US Department of...more

US Sanctions as Diplomacy Tools and Political Weapons: Complexities and Opportunities for the Business Community

Sanctions: Why So Hot Now? - In response to a number of foreign policy crises encountered over the past few years, the Obama Administration has sought a new and more aggressive approach to using sanctions to advance US...more

Crimea-related Developments: OFAC Issues Authorizations for Certain Crimea-related Communications Activity and Personal...

On January 30, 2015, the US Department of the Treasury’s Office of Foreign Assets Control (OFAC) issued three General Licenses, authorizing certain personal remittances, the operation of personal accounts and certain mail and...more

U.S. Shift in Policy Eases Cuba Sanctions and Opens Door for New Opportunities

The Obama Administration recently announced it will undertake efforts to repair diplomatic relations between the U.S. and Cuba and end decades of political estrangement and economic isolation of the island nation....more

FinCrimes Update - January 2015, Volumn 2, Issue 1

In This Issue: - BSA/AML & OFAC | FCPA & Anti-Corruption | Criminal Enforcement ...more

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